Personal Information Collection Statement – Direct Marketing

This Personal Information Collection Statement (“PICS“) sets out the policies and practices of Silverhorn Investment Advisors Limited (“Silverhorn” or “us“) with regard to your personal data.

Purpose of Collection

From time to time, you may provide us with personal information, from which your identity may be directly or indirectly determined (“personal data”), in connection with your request to receive insights, investment materials, and other Silverhorn publications (“Services”), and/or registration to events, seminars, forums, or other functions organised or sponsored by us, our affiliates, partners, or trusted third-parties.

Provision of personal data is voluntary. Any request for your personal data will only be for that we need in connection to the Services. However, failure to supply us with the requested information may result in delay or inability for us to provide the Services.

Use of Personal Data

The personal data provided in any form and any subsequent communications will be used by Silverhorn for one or more of the purposes listed below.

For provision of the Services and direct marketing including:

• providing you with information, updates, market outlook and research materials;
• providing you with marketing materials and information on financial services, products and investment opportunities offered by us, our affiliates, partners or trusted third-parties;
• inviting you to events, seminars, forums or other functions organised or sponsored by us, our affiliates, partners or trusted third-parties; and
• providing you with marketing and advertising materials (e.g. newsletters via e-mail, online advertising) and information on charity or not-for profit events or opportunities.
• any other purpose specified in any form or document that requests your personal data.

For meeting our legal and regulatory obligations including:

• meeting our legal and regulatory obligations in relation to confirming investor status and eligibility, and record keeping.

The above services may be provided to you or solicited by us, any Silverhorn Group companies, partners or trusted third-parties that we work with. In addition to us marketing the above services and products, we also intend to provide your personal data described above to all or any of these parties for use by them in marketing those services, products and subjects, and we require your consent (which includes as indication of no objection) for that purpose.

Disclosure and Transfer of Personal Data

Personal data held by us will be kept confidential, but we may disclose your personal data to the following parties where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services:

• any holding company, subsidiary, affiliate or fund under management of Silverhorn, each being a member of the “Silverhorn Group”;
• any agent, contractor, or third-party service provider who provides administrative, research, design, IT, marketing, telecommunications, printing, mailing, computer, or other services to Silverhorn Group in connection with the operation of its business;
• any other party (including but not limited to, any regulatory authorities, governmental authorities, tax, law enforcement authorities) entitled thereto by law or regulation.

Such persons may be located outside of Hong Kong and your personal data may be transferred to that location.

Withdrawal of Consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Access to and Correction of Personal Data

You have the right to request access to and correction of your personal data in accordance with the provisions of the PDPO and to the extent permissible by the applicable laws and regulations, including the right to obtain a copy of your personal data we hold about you, and information about the ways in which we use or disclose your personal data.

Any such requests should be submitted in writing or via email to our Data Protection Officer at the contact details provided below.

Protection of Personal Data

We are committed to protecting the security of your personal data and safeguard the data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and constantly review and enhance our information security measures. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure.

Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

Retention of Personal Data

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

Data Protection Officer

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Data Protection Officer

Silverhorn Investment Advisors Limited
18/F, 100QRC
100 Queen’s Road Central
Hong Kong

[email protected]